The doctrine of priest–penitent privilege does not appear to apply in English law. The orthodox view is that under the law of England and Wales privileged communication exists only in the context of legal advice obtained from a professional adviser. A statement of the law on priest–penitent privilege is contained in the nineteenth century case of Wheeler v. Le Marchant: Justification of the rule The foundation of the rule protecting communications to attorneys and counsel was stated by Henry Brougham, 1st Baron Brougham and Vaux, Lord Chancellor, in an exhaustive judgment on the subject in the case of Greenough v. Gaskell (1833) 1 Mylne & Keen 103, to be the necessity of having the aid of men skilled in jurisprudence for the purpose of the administration of justice. It was not, he said, on account of any particular importance which the law attributed to the business of people in the legal profession or of any particular disposition to afford them protection, though it was not easy to see why a like privilege was refused to others, especially to medical advisers. A similar opinion was expressed by Sir George James Turner, Vice-Chancellor in the case of Russell v. Jackson (1851) 9 Hare 391, in the following words: Moreover, in the relationship of lawyer and client the privilege was confined to communications between them made in respect of the particular litigation and it did not extend to communications generally passing between a client and his lawyer professionally. But the principle has developed so as now to include all professional communications passing in a professional capacity, and to the information and belief founded thereon, see: Minet v. Morgan (1873) 8 Chancery Appeals, 366; Lyell v. Kennedy (1883) 9 AC 90. In the former case Roundell Palmer, 1st Earl of Selborne, Lord Chancellor, said: Various commissions on law reform have opposed any extension to the current scope of professional privilege. History Pre-reformation Before the Reformation, England was a Roman Catholic country and the Canon law was the law of England. Thus the Seal of the Confessional had great import in the civil courts. From Reformation to nineteenth century During the Reformation, the Church of England was established when King Henry VIII broke from the Roman Catholic Church. The respect of the courts for the Seal of the Confessional was less compelling during this period. During the trial of Fr. Henry Garnet, for conspiracy in